^ 

z	^, -= J 

~ ____^ = 

OFFICE OF THE GOVERNOR 

RICK PERRY 

GOVERNOR 

January 27, 2014 

The Honorable Gina McCarthy 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Ariel Rios Building, Room 300 

Washington, D.C. 20460 

RE: Petition for Waiver Under Clean Air Act Section 211(o)(7)(A) 

Dear Administrator McCarthy: 

In 2008, 1 requested a partial waiver of the Renewable Fuel Standard (RFS) mandate for ethanol 

derived from grain, citing the negative economic affects the mandate has on Texas producers, 

consumers and commuters. In 2012, I wrote in support of a full or partial waiver request by 

fellow governors and other leaders when, with more than 55 percent of the country's pastureland 

damaged by drought, the ethanol mandate threatened to compromise crop yield and overall 

production. Today, I am writing in support of the recent petition for a partial waiver of the 2014 

applicable volumes of RFS by the American Petroleum Institute and American Fuel and 

Petrochemical Manufacturers. 

Today, more than 50 percent of the country is experiencing abnormally dry to exceptional 

drought conditions, a trend the U.S, drought monitor expects to persist over the next 12 months. 

While the impacts of drought will continue to threaten U.S. and Texas farrriers and producers, 

this year, we are faced with another challenge created by RFS. While renewable fuel 

requirements are increasing annually, gasoline demand in the United States is steadily declining. 

This dynamic has created the E10 blendwall — the point at which more renewable fuel is 

required to be blended than can be safely consumed in the United States, due to fundamental 

constraints imposed by fueling infrastructure and problems of gasoline engine incompatibility 

with increased ethanol blends. 

The mandate currently.xequires U.S: gasoline suppliers'tb de`monstrate compliance with' RFS 

through Renewable Identification Numbers (RTNs); The nurriber of RINs available f s tied 

directly to the level of consumption of renewable fuels in U.S. transportation fuels. As RFS 

PosT OFFIcE Box 12428 AusTBa, TExns 78711 (512)463-2000 (VoicE)/Dw 7-1-1 FOR RELAY SEEvIcEs

VIstT WWW.TEJLISONIINE.COM THE OFF1cIAL WEB s[TE OF THE sTi1TE oF TEXAs
The Honorable Gina McCarthy 

January 27, 2014 

Page 2 

mandates exceed the ability of the underlying fuel supply and vehicle and infrastructure 

compatibility to accommodate additional amounts of renewable fuels, there will be a shortage of 

RINs available for compliance, thereby limiting supplies of gasoline and diesel for U.S. 

consumption. Such a shortage will result in severe economic harm to consumers and the overall 

economy if not corrected now. 

Your agency has rightfully acknowledged the blendwall and exercised its authority in the 

proposed 2014 RFS volumes ruly waiving the volumes to just below 10 percent ethanol. I ^ 1'r 

strongly encourage you to stay the course and remain steadfast in your resolve to avoid the 

blendwall and unnecessary economic harm as you finalize the 2014 RFS volumes. Thank you 

for your consideration. 

Sincerely, 

/ tr l^-^ 

Rick Perry 

Governor 

7m,